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Chilled Food Association

CFA

CFA was formed in 1989 to establish, continuously improve and promote best practice standards in the production of retailed chilled prepared food, in sustainability, safety, skills and firmly based on science.

Lobbying Activity

Response to Update of the food safety criterion regarding Listeria monocytogenes in ready-to-eat foods

8 May 2024

CFA was founded in 1989 to establish and continuously develop best practice in the production and handling of chilled prepared (mainly composite) foods, with a focus on food safety and Lm in particular. Our members are chilled food producers meeting CFAs standards, and total ~10bn turnover. CFA is a founder member of the European Chilled Food Federation and the Industry Listeria Group (ILG). We first issued technical guidance on hygienic and safe production of chilled foods in 1989, including Lm lethal rates, production area segregation rules, hygiene management and shelf life establishment. We have continued to produce and promote best practice guidance, often with CAs (e.g. 2010 Shelf Life of RTE Food in Relation to Lm) and a range of trade, professional and research organisations. We worked with the Commission on the development of 2073/2005 (Dr Maija Hatakka) contributing hard data on HACCP verification (e.g. Day of Production and End of Life food sampling combined with production area environmental monitoring), and shelf life. We also contributed data to the EC (Dr Ari Hörmann) as part of the EUs preparation for the CODEX Hygiene Committee December 2008 session. At that meeting it was agreed that the EUs 100cfu/g gave an acceptable level of food safety protection, as shown by the EUs then listeriosis rate of ~0.3/100k. The Microbiological Criteria for Lm in RTE Foods and guidance to CAs on environmental monitoring and process control were accepted, preserving the approaches taken in Europe and the US. There is no conflict between 2073/2005 Lm requirements and CCFH, contrary to the ECs statements. Despite a plethora of guidance (see examples in Industry Listeria Groups submission) being issued and promoted before and after 2073/2005 and CCFH 2008 it is apparent from the EUs now double its 2008 listeriosis rate, that the legislation and guidance are not being enforced effectively or risk-focused in those countries where rates have escalated. The current legislation is effective when enforced. It does not need to be changed. The approach to shelf life set out in 2073/2005 is clear, i.e. HACCP-focused, backed up by verification data - DOP, EOL + environment. This is set out in our 2073/2005 implementation and 2010 shelf life guidance and backed up by our dataset of ~5 million datapoints submitted to us by our members over the last 20+ years. It was recognised already ~2001 that challenge testing does not demonstrate factory hygiene control, nor true behaviour of Lm in foods, money being better spent on hygiene measures for example. Zero tolerance (ZT) simply puts FBOs off testing and results in problems not being discovered. ZT throughout shelf life requires in-pack treatment or reformulation/addition of chemical preservatives. It is imperative that all FBOs producing/handling high risk food adopt what is perceived as best practice, but which is actually prerequisite to assure safety with respect to Lm. It is simple in principle but complex in practice. It requires significant investment by FBOs, their RTE suppliers/raw material growers (particularly for raw RTE foods), distributors and retailers/foodservice businesses, and improvements in domestic storage. There are no shortcuts. Verification of control requires a stream of data. Spot checks of product on the market do not address any root cause. Enforcement must be risk-based and targeted as CA resources are not unlimited. FAO/WHO (2023) reported that post-process environmental contamination was the primary root cause of listeriosis outbreaks where a root cause was identified. Lack of detailed EU-level guidance on this is an omission that European industry has worked together on to address in its 2023 Guidance enclosed in the ILG submission. The attachment is various Lm-focused guidance proven to be effective in reducing risk. It needs to be respected, reflected in legislation and enforced widely. https://chilledfoodassociation.myshopify.com/search?q=listeria
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Response to Commission Regulation setting maximum residue levels for chlorate in or on certain products

11 Feb 2019

The Chilled Food Association (CFA) represents manufacturers supplying the UK’s EUR 13 billion chilled prepared food market, ~95% of which is sold under retailers’ own label. This market is the largest in Europe, with >12000 SKUs ranging from prepared leaf, dressed & protein salads, sandwiches & wraps, sushi, delicatessen products, fresh pasta, pizza, ready meals, dips, dressings, sauces, soups, desserts, etc. We work from farm to fork with our members to assure food safety & hygiene best practice & legal compliance. Our major concern regarding proposed chlorate MRLs for food commodities is that this is not the appropriate legal approach given chlorate has not been used as a PPP for some 15 years in the EU, & chlorate traces arise in European foodstuffs primarily from hygiene biocides to assure safety, e.g. from the chlorination of water used for drinking, crop irrigation, as an ingredient, & in cleaning, disinfection and rinsing. The appropriate regulatory tool is contaminants legislation. It is not in the interest of either consumers or the industry for legislation to threaten the continuing ability of FBOs to assure food safety, as the current approach will do. Legislation should not inadvertently negatively impact on the availability of effective disinfectants vital to assure food hygiene through the food chain. Since chlorate traces are directly related to biocides used to assure food hygiene & safety it is vital to take a risk, not hazard-based approach to their regulation. Given the very close linkage of water treatment with chlorate traces arising in foodstuffs, regulation of chlorate in food commodities must be integrated with the Drinking Water Directive to protect public health both in terms of food microbiology and biocides traces & compounds arising from their use. Water chlorination is a primary public health control measure internationally, & should not be taken for granted. Chlorination is straightforward to use & control to ensure that minimum amounts are used to the greatest effect. From an irrigation & produce washing perspective, if no biocides are used then there has to be a plentiful supply of single-use potable water, which would greatly increase demands on the environment, affecting sustainability. It is important to note that there are no mitigation measures for chlorate traces whilst protecting food hygiene and safety, & there are no agreed standard validated methods for food material sample preparation, which has been shown to result in widely varying data for the same crops: horticulture.ahdb.org.uk/sites/default/files/research_papers/CP%20154a_Report_Final_2016.pdf. This renders the proposed MRLs unenforceable. MRLs are not related to safety, but to Good Agricultural Practices. However, since chlorate traces arise from natural bioaccumulation in leafy crops from environmental sources including irrigation water, & in final products from multiple possible exposure routes from hygiene biocides, the GAP concept has no meaning here. In addition, the MRLs have been proposed on the basis of relatively low numbers of samples. Document Pt. C 03.00 of Sept 2018 refers to the min no. samples needed for “statistically robust estimation: 60 samples for p95, 29 sample for p90, 11 samples for p75, 6 samples for the median”. The range of data sources used to propose MRLs does not represent the full scope of EU production practices nor processes used, including chlorination of water for public safety. Proposed spices MRLs are set at 0.07mg/kg but considering proposed MRLs for some source raw materials & considering a likely processing factor of x10, it would be expected that these MRLs could be exceeded. FBOs' need to be able to protect hygiene for public health by using effective hygiene biocides responsibly. A full risk assessment of impacts of chlorate regulation on hygiene including water needs to be carried out. Applying risk-based contaminants law to chlorate in food & water is appropriate.
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